- 2 - other court, and this opinion shall not be treated as precedent for any other case. Respondent determined a deficiency in petitioners’ Federal income tax for 2004 of $875. The sole issue for decision is whether petitioner Bert A. Hedrick was an active participant in qualified retirement plans in 2004 and was thus ineligible to deduct a $3,500 contribution to an individual retirement account under section 219. Background Some of the facts have been stipulated, and they are so found. We incorporate by reference the parties’ stipulation of facts at trial and accompanying exhibits. At the time the petition was filed, Bert A. Hedrick (Mr. Hedrick) and Julie L. Hedrick (Mrs. Hedrick), jointly referred to herein as petitioners, resided in Colorado. Mr. Hedrick was employed by the Jefferson County Public Schools (school system) for 28 years. During the time he was employed there, Mr. Hedrick was an active participant in the school system’s defined benefit retirement plan. He contributed a percentage of his paycheck to a retirement account through the plan, and his employer matched a percentage of that contribution. He retired on May 31, 2004. In addition to his employment with the school system, Mr. Hedrick worked part time with the Denver Theatrical StagePage: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007